Date: 09-02-2015

Case Style: Lawyer Marketing Services, Inc. v. Brad Post, Chad Stephens, Garron Rose and Movement, Inc.

Case Number: CJ-2013-5209

Judge: Dana Kuehn

Court: District Court, Tulsa County, Oklahoma

Plaintiff's Attorney: Jason Messenger and Chuck Richardson

Defendant's Attorney: Jason Taylor, Isaac Ellis and Ryan Scharnell

Description: Tulsa, OK - Lawyer Marketing Services, Inc. sued Brad Post, Chad Stephens, Garron Rose and Movement, Inc. on violation of uniform trade secret act theories claiming:

1. Plaintiff Lawyer Marketing Services, Inc. is a for-profit Corporation, organized under the laws of the State of Oklahoma with its principal place of business located in Tulsa County, State of Oklahoma.
2. Upon information and belief Defendant Brad Post (“Post”) currently is, and at all times relevant hereto was, domiciled and residing in Tulsa County, State of Oklahoma.
3. Upon information and belief, Defendant Chad Stephens (“Stephens”) currently is, and at all times relevant hereto was, domiciled and residing in Tulsa County, State of Oklahoma.
4. Upon information and belief, Defendant (3arron Rose (“Rose”) currently is, and at all times relevant hereto was, domiciled and residing in Canadian County, State of Oklahoma.
5 * Upon information and belief, Defendant Movement, Inc. (“Movement”) is an unregistered corporation with its principal place of business in Tulsa County, State of Oklahoma.
6. Upon information and belief, Defendants Post, Stephens and Rose operate Movement as ajoint venture.
7. Jurisdiction is proper in this Court because the amount of relief sought is greater than $10,000 and the Court has personal and subject matter jurisdiction over the parties and causes of action asserted herein.
8. Venue is proper because the events that give rise to the cause of action occurred in Tulsa County and all Defendants reside and may be served in Tulsa County.
FACTUAL ALLEGATIONS
9. Paragraphs 1 through 8 are hereby incorporated by reference in their entirety.
10. Plaintiff Lawyer Marketing Services, Inc. (“Plaintiff’ or “LMS”) is an attorney- marketing firm established to assist law firms in building their client base and track marketing dollars.
11. Most notably, LMS provides its clients with website development and Search Engine Optimization.
12. On January 1, 2012, LMS hired Defendant Brad Post (“Post”) based on his previous sales experience.
13. On April 9, 2012, LMS hired Defendant Chad Stephens (“Stephens”) based on his prior sales experience.
14. At the time of their hiring by LMS, Post and Stephens had no experience in website development or Search Engine Optimization, but instead received training from LMS.
15. At the time of his hiring, Post instructed LMS that his ultimate goal was to start a church in Bixby, Oklahoma.
16. LMS and Post agreed that LMS would employ Post until the church was operational, at which point LMS and Post would work on a transition plan.
17. During their employment, Post and Stephens signed a Company Property Statement, the relevant portions of which stated:
All data temporarily or permanently received, collected, downloaded, uploaded, copied and/or created on company computers, and all data temporarily or permanently received collected, downloaded, uploaded, copied and/or created on non company computers used for company business that relates in any manner to the company’s business is subject to monitoring by the company, is the exclusive property of the company and may not be copied or transmitted to any outside party or used for any purpose not directly related to the business of the company...
Upon termination of employment, an employee shall not remove any hardware, equipment, software or data from company-owned computers and shall completely remove all data collected, downloaded and or created on non-company computers used for company business that relate in any manner to the company’s business...
Employees are strictly prohibited from using company computers, company e-mail and company voice mail systems, and company internet access accounts, or personal computers used for company business, for any improper purpose...
By signing I have read and understand pages 22-26 of the company employee manual. I also understand that I am to return all company property within 10 days upon termination of my employment at Lawyer Marketing Services...
18. During their employment, Post and Stephens were provided with the pricing terms, contract terms and contact list of LMS’s clients.
19. In January 2013, Post had a location and opened the doors to his church, but continued to be employed by LMS.
20. In March 2013, Post also started a lawn care company called The Grass Roots Lawn Care, LLC.
21. While continuing to be employed with LMS, Post began promoting Grass Roots and meeting concerning Grass Roots during LMS business hours.
22. On May 10 and 11, 2013, LMS approached Post about becoming focused in his employment with LMS or alternatively to put together a transition plan to allow Post to focus all of his time and energy on the church and Grass Roots.
23. In response, on May 15, 2013, Post gave his two-week notice to LMS, but stated he would rather not come to work during the final two weeks.
24. LMS continued to pay Post his salary up and until June 1,2013.
25. On June 4, 2013, Post launched another new company with co-founder Defendant Garron Rose (“Rose”), Defendant Movement Inc. (“Movement”).
26. Movement operates as a marketing company offering website design and Search Engine Optimization.
27. Movement’s business model and marketing plans are based entirely on information gained by Post while employed by LMS.
28. On July 15, 2013, Stephens e-mailed LMS, stating that he would no longer be returning to LMS and could not give two weeks notice.
29. Stephens advised that God was moving him toward something new with a company that was a better fit.
30. Stephens joined Post and Rose in Movement.
31. Upon receiving notice that Stephens was quitting, LMS immediately began changing the passwords to Stephens accounts.
32. LMS learned that Stephens had deleted all of his incoming and outgoing LMS emails.
33. LMS learned that Stephens had deleted all of his appointments that had been set for the next few weeks.
34. LMS learned that records had been changed in the database and LMS’s entire list of clients had been downloaded.
35. On July 16, there were two attempted logins to LMS’s database “Salesforce” using Stephens’ old ID.
36. The attempted login came from an IP address associated with BTC broadband out of Bixby.
37. Upon information and belief, Post’s home in Bixby uses BTC broadband.
38. Once Movement was launched, seven (7) different LMS customers tenninated their contracts with LMS.
39. The monthly loss for these seven (7) contracts is $7,098.
40. Upon information and belief, these seven (7) contracts signed up with Movement.
41. Upon information and belief; Movement contacted numerous other customers that were prepared to sign contracts with LMS.
42. Consequently, these prospective customers failed to signed contracts with LMS.
43. Upon information and belief; Defendants have also taken steps to solicit LMS’ s top sales representative.
44. Post and Stephens used their knowledge of LMS’s pricing, calculations, contract terms and customer lists to gain a competitive advantage in the market.
45. As a consequence of Defendants’ actions, LMS has lost more accounts since Movement’s launch than in all previous years since inception of LMS.
46. As a consequence of Defendants’ actions, LMS has lost a minimum of $85,176.00 in current contracts.
47. As a consequence of Defendants’ actions, LMS has lost numerous future contracts.
48. As a consequence of Defendants’ actions, LMS has suffered damages to its reputation with current and prospective customers.
49. Defendants’ actions against LMS, as described above, were willful and malicious.
CA USES OFACTION
I. VIOLATION OF THE UNIFORM TRADE SECRETS ACT (Post & Stephens)
50. Paragraphs 1 through 49 are hereby incorporated by reference in their entirety.
51. Plaintiff’s client lists, contracts, and pricing constitute trade secrets as defined by
78 0.5. § 86(4) because they derive independent economic value to LMS, are not readily ascertainable by proper means to other persons who can obtain economic value from their use, and are the subject of efforts to reasonably maintain their secrecy.
52. Defendants Post and Stephens, using the improper means of theft, breach of a duty to maintain secrecy, and attempted electronic espionage, misappropriated the trade secrets of LMS.
53. As a consequence of Defendants Post’s and Stephens’ misappropriation of Plaintiffs trade secrets, Plaintiff has suffered actual damages of at least $85,176.00.
54. Plaintiff is entitled to recover actual damages of at least $85,176.00.
55. Plaintiff is also entitled to recover the value of Defendants’ use of Plaintiffs trade secrets as unjustenrichment caused by Defendants’ misappropriation.
56. Due to the willfhl and malicious nature of Defendants’ misapprepriation, Plaintiff is entitled to exemplary damages in the amount of twice the damages included in paragraphs 54 and 55 above.
57. Nirsuant to 78 O.S § 89(3), Plaintiff is entitled to its attorney’s fees.
H. REQUEST FOR INJUNCTION (All Defendants)
58. Paragraphs I through 57 are hereby incorporated by reference in their entirety.
59. Based on Defendants’ actions as stated herein above, Plaintiff anticipates Defendants will continue to take Plaintiff’s clients.
60. For each customer taken by Defendants, Plaintiff stands to lose approximately
$350.00- $750.00 per month.
61. If allowed to continue, Plaintiff will suffer irreparable harm.
62. Plaintiff requests a permanent injunction pursuant to 12 0.8. § 1381, et seq. and pursuant to 78 0.8. § 87 to command Defendants to refrain from using Plaintiffs customer lists and contacting Plaintiff’s customers.
III. TORTIOUS INTERFERENCE (All Defendants)
63. Paragraphs I through 62 are hereby incorporated by reference in their entirety.
64, Plaintiff had contracts with its clients.
65. Defendants knew about the contracts between Plaintiff and its clients as a consequence of Post and Stephens employment with Plaintiff.
66. Defendants interfered with the contracts.
67. Defendants’ acts were intentional.
68. Defendants used improper and unfair means.
69. As a direct result of Defendants’ actions, Plaintiff has suffered damages.
IV. CONVERSION (Post and Stephens)
70. Paragraphs 1 through 69 are hereby incorporated by reference in their entirety.
71. Plaintiff was the owner of and had the right to possess the customer lists and customer appointment information for Plaintiff’s business.
72. Plaintiffs customer lists and customer appointment information constitutes Plaintiff’s personal property.
73. Defendants Post and Stephens intentionally took possession of Plaintiff’s customer lists and destroyed customer appointment data from Plaintiff’s system.
74. Plaintiff did not consent to Defendants’ possession and destruction of Plaintiffs property.
75. Defendants Post and Stephens used Plaintiffs customer lists and customer appointment information as if the property was theft own.
76. As a direct result of Defendants’ conduct, Plaintiff has suffered damages.
V. CIVIL CONSPIRACY (All Defendants)
77. Paragraphs I through 76 are hereby incorporated by reference in their entirety.
78. Defendants combined their efforts to misappropriate Plaintiffs trade secrets.
79. As a consequence of Defendants’ actions, Plaintiff has suffered damages.


AGREED PROTECTIVE ORDER
The parties have informed the Court that certain documents and information have been and may be sought, produced or exhibited by and between the parties in this proceeding (the “Proceeding”) and that some of these documents may relate to the parties’ and non-parties’ financial information, business practices, competitive information, or other types of sensitive information which the party making the production deems confidential. It has been agreed by the parties to the Proceeding, through their respective counsel, that to expedite the flow of discovery material and to preserve the confidentiality of certain documents and information, a protective order should be entered by the Court. The Court has reviewed the terms and conditions of this Protective Order and it shall be entered by the Court. Based on the parties’ submissions, it is hereby ORDERED that
1. Scope
a. This Order shall govern all documents, the information contained therein, and all other information produced or disclosed during the Proceeding whether revealed in a document, deposition, other testimony, discovery response or otherwise, by any party, including any non-party, in this Proceeding (the “Supplying Party”) to any other party, including any non-party, (the “Receiving Party”), when same is designated with the procedures set forth herein. This Order is binding upon the parties to the Proceeding, including their respective corporate parents, subsidiaries and affiliates as well as their respective attorneys, agents, representatives, officers and employees and others as set forth in this Order. This Order is also binding on and applies to all non-parties who receive documents or information in connection with this Proceeding.
b. Under this Order, any Supplying Party shall have the right to identify and designate as “Confidential” any document or other information it produces or provides, or any testimony given in this Proceeding, which testimony or discovery material is believed in good faith by that Supplying Party, and by the Supplying Party’s counsel, to constitute, reflect or disclose trade secret or other confidential research, development, financial or commercial information contemplated under Okla. Stat. tit. 12 § 3226 of the Oklahoma Rules of Civil Procedure (“Designated Material”).
c. “Confidential Information” as used herein means any Designated Material that is designated pursuant to this Protective Order as “Confidential” by the Supplying Party, whether it is a document, information contained in a document, information revealed during a deposition or other testimony, information revealed in an interrogatory answer or information otherwise revealed.
d. A party may designate as “Confidential” information in the possession of and supplied by a non-party if the information was transmitted to the non-party under an agreement or an obligation that it would remain confidential and the information otherwise complies with Paragraph 1(c).
e. Subject to paragraph 11(c), all documents and other materials produced in this litigation shall be used only for purposes of this litigation whether or not a Supplying Party designates such documents or materials as “Confidential.”
2. Designation of Confidentiality
Documents or information may be designated CONFIDENTIAL within the meaning of this Order in the following ways:
a. Specific documents produced by a Supplying Party shall, if appropriate, be designated as “Confidential” by marking the first page of the document and each subsequent page thereof containing Confidential Information with the legend: “CONFIDENTIAL” or “CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER.”
b. In the case of interrogatory answers and responses to requests for admissions, if appropriate, designation of Confidential Information shall be made by means of a statement in the answer or response specifying that the answer or response or specific parts thereof are designated “CONFIDENTIAL.” The word “CONFIDENTIAL” shall be placed on each page of interrogatory answers or responses to requests for admission containing Confidential Information.
c. In the case of depositions and the information contained in depositions (including exhibits), designation of the portions of the transcript (including exhibits) which contain Confidential Information shall be made by a statement to such effect on the record in the course of the deposition by counsel for the party or witness producing such information, or by letter from such counsel within thirty (30) days of receipt of the deposition transcript or copy thereof (or written notification that the transcript is available). The entire deposition transcript (including exhibits) shall be treated as Confidential under this Order until the expiration of the above-referenced thirty-day period for designation by letter, except that the deponent may review the transcript of his or her own deposition during this thirty-day period. Thereafter, the page(s) on which Confidential Information appears on shall be treated as confidential in accordance with this Order.
d. To the extent that matter stored or recorded in the form of electronic or magnetic media (including information, files, databases, or programs stored on any digital or analog machine-readable device, computers, discs, networks or tapes) (“Computerized Material”) is produced by any party in such form, the Supplying Party may designate such matter as “CONFIDENTIAL” by cover letter referring generally to such matter or by affixing to such media a label identifying the item(s) as “CONFIDENTIAL”. Whenever any party to whom Computerized Material designated as “CONFIDENTIAL” is produced reduces such material to hard-copy form, such party shall mark such hard-copy form as “CONFIDENTIAL”.
e. To the extent that any party or counsel for any party creates, develops or otherwise establishes on any digital or analog machine-readable device, recording media, computer, disc, network, tape, file, database or program information designated CONFIDENTIAL, that party and/or its counsel must take all necessary steps to ensure that access to such media is properly restricted to those persons who, by the terms of this Order, may have access to Confidential Information, and will mark such items as “CONFIDENTIAL”.
f. The filing of any documents and materials with the Court containing or reflecting the contents of Confidential Information shall be filed under seal. NO SEALED FILINGS SHALL BE MADE PRIOR TO: (1) THE FILING OF A MOTION, AND (2) AN ORDER GRANTING SUCH MOTION. If the motion is granted, such documents and materials shall be labeled “CONFIDENTIAL - SUBJECT TO COURT ORDER” and shall also bear the legend “FILED UNDER SEAL” on the cover page of the document. Only those portions of such documents and materials containing or reflecting Confidential Information shall be considered Confidential and may be disclosed only in accordance with this Order. Each party shall use its best efforts to minimize filings that necessitate the filing of documents and materials designated Confidential under seal. This provision does not relieve the filing party of serving the document on other parties in accordance with ordinary procedures established by the civil and local rules or Court order. Regardless of any provision in this Order to the contrary, a party does not have to file a document under seal if the Confidential Information contained or reflected in the document was so designated solely by that party.
g. Documents filed under seal may be unsealed at the Court’s discretion.
3. Use of Confidential Information
Subject to Paragraph 11(c), Confidential Information shall not be used by any person, other than the Supplying Party, for any purpose other than conducting this action, and in no event shall such information be used for any business, competitive, personal, private, public or other purpose.
4. Disclosure of Confidential Information
a. The attorneys of record are responsible for employing reasonable measures, consistent with this Order, to control access to, and distribution of information designated “CONFIDENTIAL” pursuant to this Order.
b. Subject to Paragraph 6 below, access to information designated “CONFIDENTIAL” pursuant to this Order shall be limited to the following persons:
i. The parties, including outside and in-house counsel for the parties, as well as members and employees of their firms including but not limited to their paralegals, investigative, secretarial and clerical personnel who are employed by and engaged in assisting such counsel in this Proceeding.
ii. Outside photocopying, data processing or graphic production services employed by the parties or their counsel to assist in this Proceeding.
iii. Any outside expert or consultant (or any employee of such outside expert or consultant) who is retained, or sought to be retained, by counsel for a party in this Proceeding, for purposes of consulting, and/or testifying in this Proceeding, and to whom counsel in good faith has deemed disclosure of such “CONFIDENTIAL” material is reasonably necessary in order to assist in the preparation or the conduct of this Proceeding. This paragraph shall not relieve, change or otherwise affect any obligations or limitations imposed on any person by contract or law regarding the disclosure or use of trade secrets or other confidential or proprietary information.
iv. Any fact witness, at the witness’s deposition in this Proceeding, but
only if counsel who discloses “CONFIDENTIAL” information to the witness determines, in good faith, that such disclosure is reasonably necessary and appropriate to assist in the conduct of this Proceeding.
v. This Court or any other Court exercising jurisdiction with respect to this litigation, Court personnel, jurors, and qualified persons (including necessary clerical personnel) recording, taking or transcribing testimony or argument at any deposition, hearing, trial or appeal in this litIgation; and
vi. Any other person to whom the Supplying Party agrees in writing or on the record in advance of the disclosure, provided that the party seeking to make the disclosure must first submit a request, in writing or on the record, to the Supplying Party explaining why the disclosure is necessary. If the Supplying Party does not agree to allow the disclosure, the party seeking to make the disclosure may file a motion with the Court for approval to make the disclosure.
5. Notification of Protective Order
Confidential Information shall not be disclosed to a person described in paragraphs 4(b)(iii), 4(b)(iv), 4(b)(vi) unless and until such person has executed an Agreement of Confidentiality in substantially the form attached hereto as Exhibit A. The originals of an executed Agreement of Confidentiality shall be maintained by counsel for the party who obtained it until the final resolution of this litigation.
6. Use of Confidential Information at Trial
The rules and procedures governing the use of Confidential Information at trial shall be determined by the Court at the final pretrial conference.
7. Objections to Designations
a. A party may, at any time, make a good faith challenge to the propriety of a Confidential Information designation. In the event a party objects to the designation of any material under this Order, the objecting party shall consult with the designating party to attempt to resolve their differences. If the parties are unable to reach an agreement as to the proper designation of the material, after giving notice to the designating party, the objecting party may apply to the Court for a ruling that the material shall not be so designated. If such a motion is made, the designating party has the burden of establishing that the designation is proper. If no such motion is made, the material will retain its designation. Any documents or other materials that have been designated “CONFIDENTIAL” shall be treated as Confidential until such time as the Court rules that such materials should not be treated as Confidential.
8. Preservation of Rights and Privi1çgç
Nothing contained in this Order shall affect the right, if any, of any party or witness to make any other type of objection, claim, or other response to discovery requests, including, without limitation, interrogatories, requests for admissions, requests for production of documents or questions at a deposition. Nor shall this Order be construed as a waiver by any party of any legally cognizable privilege to withhold any Confidential Information that the parties seek to avoid disclosure of in this litigation for competitive reasons and which they feel necessary to withhold pending further agreement of the parties or an order of this Court.
Further, this shall not operate as a waiver of any right which any party may have to assert such privilege at any stage of this litigation.
9. Return or Destruction of Materials
Within thirty (30) days after the final resolution of this litigation, all Confidential Information shall be returned to counsel for the party or non-party that produced it unless the parties agree in writing to destruction. As to those materials that contain or reflect Confidential Information, but that constitute or reflect counsel’s work product, counsel of record for the parties, or non-parties, shall be entitled to retain such work product in their files in accordance with the provisions of this Order, so long as it is clearly marked to reflect that it contains information subject to this Order. Such materials may not be used in connection with any other proceeding or action. Counsel shall be entitled to retain pleadings, affidavits, motions, briefs, other papers filed with the Court, deposition transcripts, and the trial record (including exhibits) even if such materials contain Confidential Information, so long as such materials are clearly marked to reflect that they contain information subject to this Order and may not be used in connection with any other proceeding or action.
10. Inadvertent or Unintentional Disclosure
A Supplying Party that inadvertently fails to designate discovery material as “Confidential” or mis-designates discovery material as “Confidential” or pursuant to this Order at the time of its production shall be entitled to make a correction to its designation within a reasonable time of the discovery of the non- or mis-designation. Such correction and notice thereof shall be made in writing, accompanied by substitute copies of each item of discovery material, appropriately designated. Those individuals who received the discovery material prior to notice of non- or mis-designation by the Supplying Party shall within five (5) days of
receipt of the substitute copies, take reasonable steps to destroy or return to the law firm representing the Supplying Party all copies of such mis-designated documents. The obligation to treat such material pursuant to the corrected designation shall be prospective only, and those individuals who reviewed the mis-designated discovery material prior to notice of the mis-designation by the Supplying Party shall abide by the provisions of this Order with respect to all future use and disclosure of any information contained in the mis-designated materials.
11. Other Provisions
a. The restrictions set forth in this Order shall not apply to documents or information designated Confidential that are publicly available or that are obtained independently and under rightful means by the Receiving Party, unless they became so due to a violation of this Order.
b. A party’s compliance with the terms of this Order shall not operate as an admission that any particular document is or is not (a) confidential, (b) privileged or (c) admissible in evidence at trial.
c. Any party or person in possession of Confidential Information who receives a subpoena (or other process) from any person (including natural persons, corporations, partnerships, firms, governmental agencies, departments or bodies, boards or associations) who is not a party to this Order, which subpoena seeks production or other disclosure of such Confidential Information shall immediately give written notice to counsel for the other party or person who produced the materials designated as Confidential. The written notice shall identify the materials sought and enclose a copy of the subpoena or other process, unless ordered otherwise by a court of competent jurisdiction. Nothing herein shall be construed to obligate the person subject to service or other process to make a motion or undertake other legal
process, or to appear before any court or administrative body in opposition to a motion or other legal process seeking production of any Confidential materials, provided such person invokes, to the extent reasonably possible, the highest level of confidentiality available under applicable law, rule, regulation, court order, or other compulsory process, at the time of disclosure of such Confidential materials.
d. Upon the final resolution of this litigation (including conclusion of any appeal), this Order shall remain in effect and continue to be binding, unless expressly modified, superseded, or terminated by consent of all parties or by Order of the Court. This Court expressly retains jurisdiction over this action for enforcement of the provisions of this Order following the final resolution of this litigation.
e. This Order shall not prevent a party from applying to the Court for relief therefrom, or from applying to the Court for further or additional protective orders, or from agreeing to modifications of this Order, subject to the approval of the Court.
f. The Court may amend, modifr or dissolve this Protective Order at any time.

Outcome: 09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
1 POST, BRAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
1 STEPHENS, CHAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
2 MOVEMENT INC
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
2 POST, BRAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
2 ROSE, GARRON
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
2 STEPHENS, CHAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
3 MOVEMENT INC
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
3 POST, BRAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
3 ROSE, GARRON
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
3 STEPHENS, CHAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
4 POST, BRAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
4 STEPHENS, CHAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
5 MOVEMENT INC
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
5 POST, BRAD
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
5 ROSE, GARRON
09-02-2015 DISPCVDMWP

DISMISSED WITH PREJUDICE
5 STEPHENS, CHAD

Plaintiff's Experts:

Defendant's Experts:

Comments: